Privacy and Cookies Policy

The controller of personal data related to the doktorio.pl service and healthcare services organised by Doktorio is PROJECT 27 LABS spółka z ograniczoną odpowiedzialnością, ul. Władysława Pytlasińskiego 16/13, 00-777 Warszawa, Poland, NIP 5214139577, KRS 0001203723, REGON 543167047, RPWDL register number 000000299212.

For matters concerning personal data, consultations and handling requests, you can write to support@doktorio.pl or to the registered office address. This Policy applies to website visitors, patients, people who contact Doktorio and people who pay for a service.

Depending on how you use the services, we process identification and contact data, including first name, surname, date of birth, PESEL number or another appropriate identifier, address, email address and telephone number; booking and payment data; answers provided in the medical questionnaire, submitted documents, medical history information and consultation records.

We also process the contents of correspondence, complaints and data rights requests. For technical support and accountability purposes, we process, among other things, IP addresses, browser data, dates and times of operations, cookie choices, and information about declarations made and documents accepted. We obtain data from you and from the people and systems involved in handling your consultation or payment.

Providing the data needed for identification, booking, settlement and safe medical assessment is a condition for providing the relevant service. Without this data, the service may not be provided. Consent to optional analytics or marketing is not a condition for receiving a consultation.

Registration, organisation of consultations and communication concerning the ordered service: performance of a contract or steps taken before entering into a contract, Article 6(1)(b) GDPR.

Provision of care and maintenance of records: applicable medical obligations, Article 6(1)(c) and Article 9(2)(h) GDPR. To the extent necessary to perform a paid contract, we also rely on Article 6(1)(b) GDPR.

Settlements and tax obligations: Article 6(1)(b) and (c) GDPR.

Handling data rights: legal obligation, Article 6(1)(c) GDPR. Security and evidence of declarations: legitimate interests, Article 6(1)(f) GDPR.

Complaints and protection of rights: as applicable, a legal obligation or legitimate interests; where health data is necessary, also Article 9(2)(f) or (h) GDPR.

Analytics and marketing measurement using optional technologies: consent, Article 6(1)(a) GDPR.

Consent to a medical consultation, acknowledgement of the Policy and consent to cookies serve different purposes. Withdrawing consent to analytics does not automatically delete medical records or documents required by law.

Medfile is used to organise appointments, communicate with patients, send notifications and maintain medical records. Consultations take place using the available chat, audio or video functions. To the extent that the Medfile provider acts on our instructions, it processes data as a processor. Doktorio remains the controller of records concerning the healthcare services it provides. The provider may have a separate role in relation to data concerning its own services and user accounts, in accordance with the applicable terms.

Form, booking, payment and declaration data is also processed in Doktorio systems. We do not limit local processing solely to the consent register. A submitted questionnaire and attachments may be stored in the Doktorio database regardless of whether an appointment is created in Medfile.

Relevant data may be accessed by authorised people who assist the patient and provide the service, and by suppliers needed to fulfil particular purposes. We use OVHcloud to host the service, API, database and email; the stated location of Doktorio infrastructure is Frankfurt, Germany. This does not mean that all other suppliers process data exclusively in that location.

Medfile, provided according to the supplier's documentation by BioStat sp. z o.o., supports medical functions and notifications, including SMS. Stripe processes payments. Google Analytics 4 is used for service usage statistics, and Meta Pixel is used to measure marketing activities. Recipients may also include providers of operational communications and entities providing accounting, advisory and claims-related services where necessary, as well as authorised public authorities.

A supplier's role depends on the process: not every supplier acts solely as our processor. For their own obligations and services, some suppliers are independent controllers. Supplier information: Medfile — https://www.medfile.pl/polityka-prywatnosci; Stripe — https://stripe.com/privacy; Google — https://policies.google.com/privacy?hl=en; Meta — https://www.facebook.com/privacy/policy/.

The use of global suppliers may involve processing outside the European Economic Area. Such a transfer requires an appropriate legal basis, such as an applicable adequacy decision or appropriate contractual safeguards. Information about the basis for a specific transfer and how to obtain information about the safeguards is available by contacting support@doktorio.pl.

Once the purpose of processing has ended, we delete or anonymise the data unless further retention is required by law or necessary to establish, pursue or defend specific claims. Retention periods and criteria apply to individual data categories rather than to the entire database without distinction.

As a rule, medical records are retained for 20 years from the end of the calendar year in which the last entry was made. The law provides different periods for certain types of records. Statutory obligations continue to apply after a consultation ends or a request to erase data is made.

We retain tax documents until the applicable archiving obligations and limitation periods expire, usually for 5 years from the end of the year in which the tax payment deadline passed; the law may extend this period.

Other booking, communication, complaint and declaration data is required to handle the relevant matter and to the extent justified by a legal obligation or the protection of claims. The retention period depends on the purpose and category of data, completion of the matter and the applicable legal period. Not all technical copies of questionnaires and files have the same retention period as medical records. You can obtain details concerning data relating to your matter by contacting us.

The lifetime of cookies in the browser is separate from the retention of server-side evidence of choices and from data settings at Google or Meta. Deleting cookies from a device does not automatically delete all data held in suppliers' systems.

We retain archived copies of the documents and statements presented when an order is placed, together with their version and language identifiers. A change creates a new revision and does not replace the text associated with an earlier statement.

To evidence the user's actions, we record the type of statement, its text or linked version, language, choice, date and time, and connection to the request. We also process the necessary technical information described in this policy. Acceptance of the Terms, acknowledgement of the privacy information and patient consents are separate actions. Changes and withdrawals of consent are documented with a history retained to the extent necessary to demonstrate lawful processing.

To maintain continuity and restore data after a failure, we create protected backups of data in Doktorio systems. We apply access safeguards and encryption appropriate to the nature of the data. Only authorised persons have access to backups to the extent necessary to manage and restore them.

Backups are retained for a limited period determined by their recovery purpose and the applicable retention policy. They are not used as an additional indefinite archive or for routine patient service. Data deleted from the primary system may remain in protected backups until their scheduled expiry. When restoring data, we take subsequent valid deletions and changes into account so that recovery does not reinstate unauthorised processing.

We use essential technologies to record privacy choices and operate requested functions. The doktorio_cookie_consent and doktorio_consent_id cookies store the choice and declaration identifier for up to 365 days; the actual period may be shorter because of browser settings or cookie deletion.

We use GA4 and Meta Pixel for analytics and marketing purposes respectively, depending on your choice. The tools may process browser identifiers and information about interactions with the service. GA4 uses, among others, the _ga and _ga_* cookies, while Meta uses, among others, _fbp and _fbc. These technologies also include browser session storage, for example to remember the source of a visit after analytics has been selected.

You may reject optional categories and change your choice through the cookie settings available in the service. Withdrawal of consent does not affect the lawfulness of processing carried out before its withdrawal. Browser settings also allow you to delete or block cookies; blocking essential functions may make the service more difficult to use. Stripe and Medfile use their own mechanisms in the parts of the service they provide, as described in their documents.

You may request access to and a copy of your data, rectification, erasure or restriction of processing and, where the applicable conditions are met, data portability, and you may object to processing. You may withdraw consent to consent-based processing and lodge a complaint with the President of the Polish Personal Data Protection Office, https://uodo.gov.pl/.

Your rights depend on the purpose and legal basis for processing. The obligation to retain medical or tax records may prevent their erasure on request. Identity verification when handling a request should be proportionate to the data and risk involved.

You may submit a request to support@doktorio.pl or through the GDPR form available in the service. We respond without undue delay, generally within one month of receiving the request. In the cases provided for by law, this period may be extended by a further two months; we will inform you of the reason within the first month.

Medical assessments are made by a doctor. We do not replace them solely with automated decision-making. Marketing tools may assign activity to audiences or groups in accordance with the consents selected and the suppliers' policies.

The controller of data submitted through this form is PROJECT 27 LABS sp. z o.o. The data is used to handle a personal data request and document the controller's compliance with its obligations, on the basis of Article 6(1)(c) GDPR. We disclose it to the people and suppliers necessary to handle the matter; we retain it for the time required to handle the matter and for a justified period to document the exercise of rights. Providing contact details and information needed to identify the request is necessary for us to respond. Your rights and contact details are described in the Policy above. Do not submit medical data in the form unless it is necessary for your request.